An Introduction to the

Safety Case Joint Work

Group (SC JWG)

Mr. Amit BhatnagarProcess Safety manager

Singapore Refining Company and SC JWG Co-Lead

Safety Case Regime shall help MHI’s to progress from

“We Think” to “We Know” for the prevention and mitigation of

major accidents

Why Safety Case Regime?

Role

• Support enhancement of Process Safety Regulatory Framework in

S’pore by developing implementation proposals for Safety Case Regime

• Coordinate with SRMC/SCIC QRA Work Group to ensure revised QRA

Guidelines are fit for adoption into Safety Case Regime

Gov. Reps

MOMMdm Jaime Lim(Co-Lead)

Acting Deputy Director (MHD)

SCDFLTC Ng Geok Meng Assistant Dir (HazMat)

Maj Lo Wai Mun Assistant Dir (Licensing)

NEA Mr. Chen Fu Yi Sr Engineer (Central Building Plan)

IndReps

SCIC

Mr. Amit Bhatnagar(Co-Lead)

Singapore Refining Company

Mr. Evert Klein ExxonMobil

Ms. Gloria Wang Shell

Safety Case Gov.- Ind. Joint Work Group (SC JWG)

SRMC = Safety & Risk Management Centre; MHD = Major Hazard Dept; QRA = Quantitative Risk Assessment

SC JWG Team Objective

• Collaborative effort by regulators and industry members under SCIC to developed guidance documents to support SC regime implementation.

• Guiding principal during document development:

– SC regime should be value driven, fit-for-purpose regime to prevent or mitigate Major Process Safety Accidents

– SC regime helps to enhance Process Safety knowledge and competency of MHI’s.

– Development of SC regime related systems, processes and documents should be done in-house by MHI’s staff to increase in-house Process Safety competency.

– Consultant services should only be used for limited scope, specialised activities (e.g. Quantitative Risk Assessment studies etc.)

Deliverables

Activities of JWG

• WSH (MHI) Regulations• Guide to MHI

Regulations

SC Technical Guidance• SC Technical Guidance • SC Assessment Guide

By Regulators

By SC JWG

• Technical Guidance & Assessment Guide being developed based on UK HSE’s guidance documents Health & Safety Guide HSG 190 – Preparing Safety Reports

Activities Status

Develop Technical Guidance (TG) for SC regulatory regime, consistent with European Seveso Directives

Completed

Develop SC Assessment Guide (AG)

Completed

Develop strategy to build industry capability in implementing SC

Completed

Identify potential opportunities to harmonise SC regime with existing regulatory requirements

Completed

• 50 SC JWG meetings conducted since 1st meeting on 5th June 2015 (3~4 hrs. every Thursday)

• SC TG document released by MHD. Soft copy available at MOM website.

• SC AG development and review completed. Draft copy released.

• Preliminary list of existing regulations to be harmonised with SC regime prepared. MHD is following up for inter-agencies alignment and way forward.

• 1 SC Leadership forum and 4 Knowledge workshop conducted(91% MHI’s and 185 participants attended)

• Industry members of JWG working with SCIC to develop Practitioner Training program (4 ~ 5 days) for MHI engineers involved in detailed development of SC related processes/ documents.

7

Status of JWG Activities

Following requirements identified for potential harmonisation:• Requirements with similar work processes and common objectives • Streamline to avoid duplication of efforts, e.g. inspection

8

Regulations Agency Comments

WSHA• Dangerous Occurrence reporting• Statutory Inspections (yearly subject to CLA)• Factory Registration (5 yearly)

• PHA (5 yearly)• SS506 Pt 3 SHMS - Audit (2 yearly)

• Design for Safety

MOM-

EPMA – Hazardous Substances • Licensing - Storage / Use (yearly)

NEA Exclude : Transport

FSA – Petroleum & Flammable Materials• Licensing - Storage (yearly)• Storage tank inspection

SCDFExclude : Transport & pipeline

EPMA & FSA – Revised QRA Guidelines NEA/SCDF -

Harmonisation of Regulatory Requirements under Safety Case

1. Descriptive information of MHI

2. Major Accident Prevention Policy (MAPP)

3. Safety Management System (SMS) description

4. Risk assessment, including predictive aspects & identification of Major Accident Scenarios (MASs)

5. Technical aspects of a Safety Case, including controls (prevention and mitigation measures) to prevent MASs from occurring

• Process safety

• Mechanical

• Electrical, controls and instrumentation

• Human factors

6. Emergency Response Plan (ERP)

7. ALARP demonstration for selected MASs

8. Review MAPP & ERP in light of any new domino info received

Main Components of a Safety Case

SC contains all information required to demonstrate that

the MHI can be operated safely.

1. Overview of the installation, its activities/processes and products

2. MHI details include main hazards due to dangerous substances as per 2nd Schedule of new WSH (MHI) Regulations

3. Maximum inventory details of dangerous substances above threshold quantities

• As raw materials, product, by-product, residue, waste or intermediates handled during normal or during abnormal foreseeable process excursions

4. Physical distribution of dangerous substances across the MHI

5. Physical & chemical properties of all listed dangerous substances, processes, MASs

6. Short & long term effects of dangerous substances present at MHI

7. Description of MHI’s vicinity including details of sensitive receptors

8. External factors which may lead to or exacerbate major accidents

9. Administrative details of the MHI including address and other information.

Descriptive Info of MHI

1. Identification of Major Accidents Hazards (MAHs) & MASs at an

MHI, based on risk to people onsite and off-site

2. Risk assessment of identified MASs using – Qualitative

– Semi-quantitative

– Quantitative methods or

– A combination of these (based on proportionality principle)

3. Selection of representative set of MASs for detailed assessment

4. Consequence & likelihood assessment of representative set of

MASs

5. Selection of Safety Critical Events from MASs for ALARP

demonstration.- Proportionality rule

- It might be impractical to perform case specific demonstrations for all MASs.

- This is a more pragmatic option, with the remaining risk generators being

monitored by the MHI in a rolling programme, leading up to the time of the

next SC submission.

Predictive Aspects of SC (Risk Assessment) (1/3)

Predictive Aspects of SC (Risk Assessment) (2/3)

Developing Linking Table (3/3) • Linking table may be developed when quantitative methodology (QRA) is used to

conduct detailed risk assessment for Safety Case.• Linking table connect scenarios used for modeling in quantitative methodology

(QRA) to initiating causes identified in qualitative studies like PHA, Hazid, Hazopetc.

• Identifying initiating causes helps to identify the control measures which are critical to prevent or mitigate this Safety Critical Events

Example Of Linking Table

Identified Safety CriticalEvent (from quantitative study)

Equivalent Scenarios from Hazop Studies

Initiating Event from Hazop/ Hazid Studies

Loss Of Containment of Hydrocarbon leading to major fire and explosion

in section A of the plant(equipment catastrophic failure)

Gas breakthrough from high pressure system to low pressure vessel leading to itsoverpressurisation and catastrophic failure and loss of containment

1. LCV yyyy from high pressure system to low pressure vessel fails to open position

2. High pressure feed pump mmmm tripped

Catastrophic failure of high pressure vessel ZZZZ

3. General thinning of vessel due to corrosion

Control Measures identified in Hazop study for these initiating events to be reviewed for adequacy

Note: Paragraph 98 on page 28 provides more details on linking tables

1. Necessary & adequate control measures (preventive & mitigation barriers) implemented to prevent MASs and limit their consequences to people on- & off-site

2. Adequate safety incorporated into control measures to prevent MASs during facility’s lifetime

3. Five main elements to show sufficient safety built into control measures:

• Design: Plant layout, process and mechanical design of equipment

• Construction: Manufacture, installation, construction, testing of equipment, structures.

• Operation: Start-up, shutdown, normal/ abnormal/ emergency operations

• Maintenance: PM programme, inspection regime, replacement philosophy

• Plant Modification: Managing changes, including decommissioning

Technical Aspects of SC (Preventive & Mitigation Measures)

Technical Aspects of SC (Preventive & Mitigation Measures)

Cause 1

Cause 2

Cause 3

Cause 4

Cause 5

Consequence 1

Consequence 2

Consequence 3

Consequence 4

Consequence 5

Preventive Measures

MitigationMeasures

Loss of Containment(Top Event)

Controls

CO

NSEQ

UEN

CES

HA

ZAR

DS

Preventive & Mitigation Measures: Use of Bow Tie Diagrams

1. Detailed description of MHI emergency response measures for all MASs

2. SC to demonstrate that MHI has taken all necessary measures to limit the consequences of a Major Accident should it happen and on-site emergency plans have taken these into account

Emergency Response Plan

1. ALARP demonstration is a new concept for Singapore

2. Demonstration that risks from MAHs are reduced to ALARP is a critical part of SC regime

- MHIs to demonstrate risks arising from SCEs are reduced to ALARP

3. Demonstrating a risk is ALARP requires MHI to justify that it is not reasonably practicable (technology, time, money, effort) to reduce the risk further

4. Different methodologies/approaches based on proportionality principle may be used for ALARP demonstration

ALARP Demonstration (1/2)

Has Good Practicebeing applied?

Identify all further risk reduction measures

Identify which risk reduction measures are reasonably practicable

Present evidence of rejected

risk reduction measures which are deemed ‘grossly

disproportionate’

Implement justified risk reduction measures

Present justification for Good Practice not

applied Yes

No

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Example Of ALARP Demonstration Process (2/2)

End Of Presentation

SC Joint Work Group Activities